RAJASEKHAR NAIDU GALLA,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATHI
Facts
The assessee, Rajasekhar Naidu Galla, filed his return for AY 2020-21, declaring income of Rs. 29,31,680. The assessment was completed under Section 143(3) r.w.s. 144B. The Principal CIT (PCIT) initiated revision proceedings under Section 263, holding the assessment order erroneous and prejudicial to revenue. The PCIT's order was challenged by the assessee.
Held
The Tribunal held that the Assessing Officer (AO) had made proper enquiries and accepted the assessee's explanation regarding the capital gains/loss from the relinquishment of rights in property. The PCIT erred in assuming jurisdiction under Section 263 as the AO's order was neither erroneous nor prejudicial to the revenue.
Key Issues
Whether the PCIT was justified in invoking Section 263 to revise the assessment order, and whether the AO's assessment order was erroneous and prejudicial to the interest of the revenue.
Sections Cited
Section 263, Section 143(3), Section 144B, Section 143(2), Section 2(14)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad
आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/The : Rajasekhar Naidu Galla, 6-7-630, Flat No.103, Srinidhi Homes, K.T. Road, Assessee Sripuram Colony, Tirupati. 2. रधजस्व/ : The Deputy Commissioner of Income Tax, The Circle – 1(1), Tirupati. Revenue 3. The Principal Commissioner of Income Tax, Tirupati. 4. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, हैदरधबधद / DR, ITAT, Hyderabad 5. गधर्ाफ़धईल / Guard file
आदेशधिुसधर / BY ORDER
Sr. Private Secretary ITAT, Hyderabad